SAR Filing Services in the UAE
Sometimes nothing has been paid, yet something is clearly wrong. A client goes quiet when you ask where their money comes from. Someone hands over an ID that does not look genuine. A deal is cancelled the moment you start asking questions. In the UAE, these situations are reported to the Financial Intelligence Unit (FIU) as a Suspicious Activity Report (SAR) on the goAML portal.
- Who files
- FIs, DNFBPs and VASPs
- When to file
- Without delay
- Covers
- Behaviour and attempts
- Legal basis
- CR 134/2025, Arts. 14 & 18
Our SAR Filing Services are built for the cases where something feels wrong but no money has moved yet. We help regulated UAE businesses recognise when behaviour is reportable, choose the right goAML report and file a clear SAR. Not yet on goAML? We take care of your goAML registration as well.
What Is a Suspicious Activity Report (SAR)?
A SAR is a goAML report about suspicious behaviour or activity that may point to dirty money, funding for terrorism or funding for weapons programmes, in cases where no specific completed payment can be described. It lets the FIU know about people and attempts that might otherwise go unnoticed.
SAR vs STR: What Is the Difference?
Both reports come from the same legal duty to report suspicion. The difference is what you are reporting:
- STR (Suspicious Transaction Report): money has moved, or a payment was attempted, and you have the transaction details.
- SAR (Suspicious Activity Report): the concern is about conduct, an approach or an attempted deal, and there is no transaction to describe.
Picking the wrong one is common. An STR without transaction data can be rejected by goAML, while a SAR filed for a real payment leaves out details the FIU needs. We check the facts before anything is submitted.
What UAE Law Says About Reporting Suspicious Activity
The law does not only cover completed payments. It also covers attempts and situations where you cannot finish your customer checks. These are the rules that make a SAR necessary:
“prohibited from establishing or continuing a Business Relationship or executing a Transaction where they are unable to apply Customer Due Diligence measures, and shall consider submitting a Suspicious Transaction Report to the Unit whenever necessary”
Cabinet Resolution No. 134 of 2025, Article 14(1)
| Law and article | What it means for your business |
|---|---|
| CR 134/2025, Art. 18(1) | The reporting duty applies to a transaction or an attempted transaction, regardless of its value. |
| CR 134/2025, Art. 14(1) | If a client will not let you complete due diligence, do not take them on or continue the relationship, and consider reporting to the FIU. |
| CR 134/2025, Art. 14(2) | If asking more questions could alert a suspect, you may stop the checks, but you must then report and explain why. |
| CR 134/2025, Art. 9(3) | You must understand the purpose and intended nature of every business relationship, which is why asking about source of funds is normal. |
| CR 134/2025, Art. 19(2) | A lawyer, notary or auditor who tries to talk a client out of an unlawful act is not treated as tipping off. |
Suspicious Activity Report Examples
- A new client refuses to show source of funds or source of wealth documents.
- A visitor presents an ID with details that do not match, or that seem altered.
- A customer asks how to stay under reporting limits or avoid paperwork.
- Someone insists on secrecy or unusual urgency for no clear reason.
- A buyer walks away from a property or gold deal right after due diligence questions.
- A client appears in credible news reports linked to fraud or other financial crime.
A Real-World Scenario
A prospect asks a corporate service provider to set up three companies in one week. When asked who the real owner is and where the start-up money comes from, the prospect stops replying and cancels. No fee was paid. The compliance officer files a SAR describing the request, the questions asked and the details the prospect gave.
Who Needs to File a SAR?
Any Financial Institution, DNFBP or Virtual Asset Service Provider registered on goAML, including real estate agents, jewellers and gold traders, accountants, auditors, company formation agents and crypto firms. Legal professionals and independent auditors are excused only for information covered by professional secrecy (Article 18(2), AML law).
How Our SAR Filing Service Works on goAML
First, your business must be registered on goAML. You cannot file a SAR without your own login. Registration runs through the FIU's SACM portal, followed by a Google Authenticator login to goAML. Once you are set up, we help you file like this:
- 01Listen to the facts: we review onboarding notes, emails and call records with your compliance officer.
- 02Confirm SAR, not STR: we check whether any transaction details exist.
- 03Identify everyone involved: names, nationalities, ID numbers and company details.
- 04Write a clear timeline: what happened, when, and why it raises concern.
- 05Attach proof: documents received or refused, screenshots and meeting notes.
- 06Submit from your account: your compliance officer approves and sends it.
- 07Handle follow-up: we help you respond if the FIU asks for more.
Do I Need to Stop Working With the Client?
Not automatically. Base the decision on your own risk assessment and any instruction from the FIU. What you must never do is tell the client about the SAR. Asking pointed questions after you have decided to report can also alert them, so plan your next steps with your compliance officer.
Mistakes to Avoid With SARs
- Thinking "no money moved, so no report".
- Writing about the client's background but not explaining why it is suspicious.
- Sending an STR with blank transaction fields.
- Keeping no record of why you decided to report, or not to report.
- Throwing away notes. Keep SAR files and supporting papers for a minimum of five years (Article 25, Executive Regulations).
What Is the Risk of Ignoring Suspicious Activity?
Staying silent is risky. A person who wilfully, or through serious carelessness, fails to report can be jailed, fined between one hundred thousand and one million dirhams, or both (Article 28 of the AML law). On top of that, the regulator may impose penalties on the company of up to five million dirhams for each breach (Article 17). Letting the client know a report was made is a separate offence (Article 29).
Why Choose Our SAR Filing Services?
- Clear advice on SAR vs STR and other goAML reports.
- Well-organised reports with a simple, factual timeline.
- Confidential handling from start to finish.
- goAML registration, login help and user setup.
- Records arranged for supervisory inspections.
Frequently Asked Questions
What is a SAR report in AML?
It is the goAML report a UAE business uses to flag worrying behaviour, approaches or attempted deals to the FIU when there is no completed payment to describe.
Do I need a transaction to file a SAR?
No. That is exactly what the SAR is for: suspicious behaviour, approaches or attempted deals.
Is there a deadline for a SAR?
Report without delay once suspicion is formed. The law does not set a fixed number of days.
Can an outside consultant submit the SAR for us?
The SAR must be sent from your organisation's goAML account. We prepare it and guide your compliance officer through submission.
Not sure if it is reportable?
Tell us what happened. We will confirm the right goAML report and help you file it.